Brazil’s Foreign Tax Credit: What Cosit Tax Ruling No. 139/2026 Means for Brazilian Service Providers
Cosit Tax Ruling No. 139/2026 now allows the income tax withheld abroad on revenues from services rendered directly to foreign customers to be credited against the IRPJ calculated for that month’s estimated payment, revising Cosit Tax Ruling No. 18/2021. The requirements for claiming the credit, the treatment of the CSLL, and the limits imposed by the RFB are examined.